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Responsible Officer (RO) FATCA Certifications are due July 1, 2021

Is your organization ready to make required RO certifications?

TAX ALERT  | 

Authored by RSM US LLP


On May 25, 2021, the IRS published an article reminding responsible officers (ROs) of offshore funds, foreign banks, and other participating or Model 2 reporting foreign financial institutions (FFI) that RO Certifications documenting their organizations’ compliance with the Foreign Account Tax Compliance Act (FATCA) for the period ending Dec. 31, 2020 are due on July 1, 2021. The certifications are generally due every three years and are only required for FFIs in jurisdictions (such as Switzerland or Bermuda) that have Model 2 intergovernmental agreements (IGAs) in effect and for FFIs in jurisdictions that have no IGA with the U.S. government for implementation of FATCA. For more details, please refer to our prior alert.

In general, ROs of FFIs in countries with Model 1 IGAs (such as Cayman Islands an United Kingdom) are not required to submit certifications, but should still review their FATCA message board and respond to the IRS’ request for confirmation that a certification is not required. Interestingly, despite ongoing challenges and business disruptions, the IRS has not granted any additional relief or extended the deadline for ROs of Model 2 Reporting FFIs to submit the required certifications. Therefore, we suggest that FFIs review their processes and controls for complying with FATCA’s due diligence, reporting and withholding requirements as soon as possible to avoid potential risk associated with noncompliance.                                                                     

To learn more about RSMs Responsible officer certification services, please visit our FATCA landing page.

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This article was written by Aureon Herron-Hinds and originally appeared on 2021-05-27.
2020 RSM US LLP. All rights reserved.
https://rsmus.com/what-we-do/services/tax/international-tax-planning/global-information-reporting/responsible-officer-ro-fatca-certifications-are-due-july-1-2021.html

The information contained herein is general in nature and based on authorities that are subject to change. RSM US LLP guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. RSM US LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein. This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer.

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